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Clarity Offered for Business Interest Expense Limitation
Posted by Claudia Mullen on Fri, Jun 14, 2019 @ 08:20 AM

The IRS released proposed regulations to provide taxpayers with guidance on applying a tax reform provision related to business interest expense deductions. The 2017 tax law commonly known as the Tax Cuts and Jobs Act (TCJA) set new limits on business interest expense deductions for most businesses, including C corporations and partnerships.

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Topics: Claudia Mullen, Tax Reform, Tax Cuts and Jobs Act, TCJA, tax reform bill, Business Interest Expense Limitation, Section 163(j)

The Impact of the New Tax Law on Pass-Through Entities
Posted by Claudia Mullen on Tue, Mar 27, 2018 @ 07:06 PM

If there are winners and losers under the new tax reform law, pass-through entities—S corporations, partnerships, LLCs, and sole proprietorships (collectively, pass-through entities)—can count themselves among the winners. The tax reform law introduced as the Tax Cuts and Jobs Act (TCJA) is primarily designed to provide tax cuts for businesses of all types, and it delivers on that goal. It also adds complexity, and in some circumstances, the potential tax savings for C corporations may outpace the savings afforded to pass-through entities. This formerly unorthodox scenario and many other new provisions for pass-through entities require careful study to ascertain the full impact of TCJA on such businesses.

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Topics: Claudia Mullen, Congress, Tax Reform, tax reform bill, pass-through entities

A Chance of Clouds: Sales Tax Considerations of Cloud Computing
Posted by Claudia Mullen on Thu, Nov 5, 2015 @ 09:30 AM

Cloud computing has revolutionized how we do business, and it continues to grow exponentially. Analysts expect the public cloud market to grow from $72 billion in 2014 to $191 billion by 20201. The rise of cloud computing has leveled the playing field for startups and mid-size businesses. It has allowed these businesses to have access to costly software, hardware and infrastructure without having to make the burdensome capital investments that would previously only be affordable for larger companies. The rise of cloud computing, however, has also brought about the rise of state taxation issues. As with all emerging technological advances, states have struggled to apply their current taxation standards to cloud computing. This struggle is most evident in the area of sales and use tax where there is no uniformity among states on how to tax or even characterize these transactions.

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Topics: Claudia Mullen, sales and use tax, cloud computing

RI Governor Signs FY2016 Budget
Posted by Claudia Mullen on Wed, Jul 8, 2015 @ 09:17 AM

On June 30, 2015 Rhode Island Governor Gina Raimondo signed the state’s $8.67 billion FY2016 budget, which became effective as of July 1. The General Assembly had previously overwhelmingly approved the tax-and-spend legislation that, according to the governor, is “intended to increase education spending for the state's youngest school children, trim the tax bill for many retirees and spur job growth.”

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Topics: Claudia Mullen, FY2016

Rhode Island General Assembly Passes FY2016 Budget
Posted by Claudia Mullen on Mon, Jun 29, 2015 @ 09:39 AM

With passage by the Senate on June 23, 2015, the General Assembly gave its approval to the state's $8.7 billion FY2016 budget, tax-and-spend legislation that eliminates state income tax on Social Security benefits for many Rhode Islanders as well as removes taxes on utilities for businesses. Specifically, the budget eliminates the sales tax that non-manufacturing businesses pay on electric, natural gas and heating fuel bills. The tax will be eliminated in FY2016 at a cost to the state of $20 million. The original proposal had the tax phased out over a five-year period at a cost of $4.9 million in FY2016.

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Topics: Claudia Mullen, Rhode Island Budget, FY2016 Budget

Cleaning Up Your Tax (Obligations) with Voluntary Disclosure Agreements
Posted by Tarra Curran on Wed, Dec 10, 2014 @ 09:22 AM
Authors: Tarra Curran and Claudia Mullen

While paying taxes might not be our favorite pastime, the overwhelming majority of taxpayers strive to file and pay all of their tax obligations. However, sometimes taxpayers' best efforts to comply with their tax obligations are not enough, especially in the state and local tax world. Although it may be an innocent mistake, such filing non-compliance may be very costly if it is first discovered by the state or local taxing jurisdiction, because the taxpayer will not only be subject to tax and interest but also harsh penalties (up to 25 percent or more). On the other hand, the taxpayer does have options to come forward and minimize its exposure if the taxpayer is the first to discover any non-compliance. Voluntary disclosure agreements, or "VDAs," are a popular and generally effective method for taxpayers to clean up their state tax compliance issues.

How Did You Not Pay Your Taxes?

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Topics: Tarra Curran, Claudia Mullen, VDA program, Voluntary Disclosure Agreements

Transfer Pricing Roadmap Gives Insight on Examination Issues
Posted by Claudia Mullen on Thu, Jun 19, 2014 @ 09:14 AM

In February 2014, the IRS Transfer Pricing Operations (TPO) team issued a Transfer Pricing Audit Roadmap. The roadmap is intended to assist IRS examination teams with identifying and auditing transfer pricing issues. The creation of this roadmap reflects the Service's increased focus on transfer pricing matters. The roadmap also gives us insight into which transfer pricing issues will be scrutinized more closely and what kind of documentation the IRS expects to be in place to support the taxpayer's position.

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Topics: Claudia Mullen, Transfer Pricing Audit Roadmap, transfer pricing

Market-Based Sourcing in Massachusetts to Begin in 2014
Posted by Tarra Curran on Thu, Sep 5, 2013 @ 09:16 AM

As part of the newly enacted transportation finance bill, effective in 2014, the Commonwealth amended the apportionment formula for multi-state taxpayers to reflect market-based sourcing.

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Topics: Tarra Curran, Market-Based Sourcing in Massachusetts, tax, Claudia Mullen

Massachusetts Enacts Sales and Use Tax on Computer Services, and Market-Based Sourcing
Posted by Claudia Mullen on Wed, Aug 7, 2013 @ 07:06 AM

Attention businesses in Massachusetts: You are likely to pay more in sales and use taxes due to the Commonwealth’s newly passed finance law.

Massachusetts lawmakers voted on July 26, 2013 to override Gov. Deval Patrick’s veto of a proposed transportation finance bill (H. 3535). The newly passed legislation – which earmarks about $800 million per year to transportation needs – is intended to remedy some of the Commonwealth’s most pressing MBTA, road and bridge problems, and limit MBTA fare increases to 5 percent each year. (In 2012, MBTA fares rose 23 percent.)

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Topics: Market-Based Sourcing in Massachusetts, Market-Based Sourcing, Massachusetts, computer and software services, Claudia Mullen, Sales Tax, sales sourcing, sales and use tax

Change Up: The Potential Evolution of the Throwback Rule
Posted by Tarra Curran on Mon, Jun 10, 2013 @ 09:25 AM

As a result of our increasingly technology-driven economy, states are refining their taxation schemes to address businesses that don't have a physical presence in the state. The driving concept behind these changes is redefining the term “nexus” as it relates to economic nexus and factor presence nexus. California's Franchise Tax Board (FTB) recently issued a chief counsel ruling addressing the application of the throwback rule in light of its adoption of factor presence nexus. This throwback rule update is applicable to businesses in states that have a throwback rule and have also adopted a factor presence nexus standard.

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Topics: Tarra Curran, Claudia Mullen, Throwback Rule

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